[FIRM LETTERHEAD OR CAPTION BLOCK]
[DATE]
[Opposing Counsel Name]
[Law Firm]
[Address]
Via [Email/ECF/Overnight Mail]
Re: [Case Name], [Court], Case No. [Number] - Discovery Deficiency Meet-and-Confer
Counsel:
We write pursuant to Maryland Rule 2-432 to address deficiencies in your [responses/production] served on [DATE]. This letter documents our good faith effort to resolve this dispute before seeking court intervention.
Maryland Discovery Rules - Key Citations
- Response deadlines: 30 days from service (Md. Rule 2-421(b), 2-422(b)); +3 days if served by mail
- Interrogatory limit: 30 interrogatories without subparts (Md. Rule 2-421(a))
- Request for Production: Md. Rule 2-422; 30 days to respond
- Motion to compel (Md. Rule 2-432(a)): Court may enter appropriate order including sanctions
- Sanctions (Md. Rule 2-433): Court may impose sanctions including fees, preclusion, and dismissal
- Baltimore City/County Local Rules: Additional requirements may apply
Specific Deficiencies and Requested Cures
| No. | Request/Topic | Deficiency | Requested Cure | Deadline |
|---|---|---|---|---|
| 1 | [Interrogatory No. __/Request No. __] | [e.g., improper objections; failure to produce documents per Rule 2-422; inadequate answers] | [e.g., provide complete verified response; produce responsive documents; provide privilege log] | [Date] |
| 2 |
Additional Issues
- Privilege log (Md. Rule 2-402(e)): [not provided/incomplete]; Maryland requires express claim of privilege with sufficient detail—please provide by [DATE] with document date, author, recipients, privilege type, and general description.
- Verification: Interrogatory answers must be verified under Md. Rule 2-421(b).
- ESI/formatting: [missing metadata/native format]; please re-produce in [reasonably usable form per Rule 2-422(b)].
- Protective order/clawback: [status]; propose to file agreed protective order by [DATE].
Maryland-Specific Sanctions Warning
Under Md. Rule 2-433, the court may impose sanctions for failure to comply with discovery obligations, including award of reasonable expenses and attorney's fees, preclusion of evidence, and dismissal or default judgment.
Maryland courts actively enforce discovery obligations and have emphasized good faith compliance with discovery rules.
Proposed Path to Resolution
- Meet-and-confer availability: [3 date/time windows] (Eastern Time). We are prepared to meet telephonically or in person.
- We propose resolving without court intervention if you confirm supplemental responses/production by [DATE].
- If unresolved by [DATE], we will file a motion to compel under Md. Rule 2-432 and seek fees and costs.
- We will reference this correspondence in our motion.
Preservation Reminder
Please confirm litigation holds remain in place for email, text messages, messaging platforms, shared drives, cloud storage, and any custodian-specific data sources relevant to the disputed requests.
We look forward to your prompt response.
Sincerely,
______________________________
[Attorney Name]
[Law Firm]
Counsel for [Party]